Royal Borough of Kingston upon Thames Guildhall II,
Kingston upon Thames,
4th November 2020
Dear Mr Feltham,
RE 20/02495/FUL – 10 & 11 Storey Office Towers and Car parking Building 20/02499/OUT – 22 Storey Residential Tower
Kingston Residents’ Alliance RESPONSE
Planning applications 20/02495/FUL and 20/02499/OUT in their current form should be rejected for the reasons set out below:
Eden Campus is the 3rd major development to seek Planning Approval in the ‘Eden Quarter’ after Eden Walk and Royal Exchange (TOPO, The Old Post Office). Whereas Eden Walk and the Royal Exchange developments largely comply with the prevailing Planning Guide, the Eden Quarter Development Brief Supplementary Planning Document 2015 - the ‘EQDB’ - the proposals for Eden Campus on the other hand, do not. Kingston residents fought hard to reduce the height of that ONE signature tower from 21 to 16 storeys. For a 22- storey tower and a 11 storey tower to be proposed 4 years later just next door “as a “cluster” makes a complete mockery of Kingston’s Planning Guides AND of the residents' hard fought previous campaigns.
There has been no Public Consultation which could justify any changes to the principles set out in the EQDB which was adopted after due process and consultation with residents.
Furthermore, proposals for the same site were resoundingly rejected on Appeal in late 2019 and these new proposals are worse in their impact.
In spite of 84% public objections made at pre-planning consultation the scheme submitted for Planning has not been amended at all.
Our Council should not lose sight of its obligation to existing and future residents and our local community, to protect and enhance our existing environment.
1. Harm to Heritage Assets and their settings, Visual Impact & Conservation Areas
If permitted, the proposals for Eden Campus would have significant detrimental effects on Kingston’s multiple Heritage Assets and their settings as seen from various strategic points around the town a number of which have been designated as Very Important Views and worthy of protection from harm. The exact same harm (and more) to Heritage Assets would be caused by the proposals as was upheld in the Planning Inspectorate’s appeal decision in 2019.
The Market Place is Kingston’s crown jewel, and this would be shattered if these proposals are permitted. We understand that the Market Place and the medieval street patterns are one of the best-preserved examples in outer London. From various vantage points it is largely untouched by modern buildings encroaching on it. These proposals would completely change this experience and dominate the skyline with an unwelcome modern and overbearing series of huge buildings. The tower would completely spoil the distinctive silhouette of the Market House by presenting a competing tower on the skyline. There would be no escape from it.
The site sits amidst multiple historic assets and conservation areas in Kingston Old Town Centre. It shows no deference to any of these nor makes any attempt to blend in. The buildings are completely out of scale for the site and conflict with the low-rise character of the historic town centre. The village-like form of the Kingston Old Town would be encroached upon by a domineering, urbanizing group of structures alien to the adjoining streetscape and townscape surroundings.
Eden Campus will dominate views of Kingston when viewed from Home Park in direct conflict with the EQDB which limits the height of ALL buildings on site to 6-8 storeys
No building should be permitted to take attention away from the delicate silhouette of the tower of All Saints Church on the overall townscape skyline. Eden Walk and Royal Exchange came perilously close, this would finish the job.
2. Height & Scale
The Office Block on Eden Street, the Office Block on Brook Street and the Residential Tower at East End of site adjacent roundabout Multi Storey Car Park on St James Rd are three of the buildings which are technically ‘towers’ as defined by the current London Plan, which Kingston Planning Guides are based on. They are each all in breach of the ‘EQDB’. If allowed “Residential Tower” element of this development will be one of tallest buildings in the borough, one to match the Tolworth Tower.
There is only meant to be ONE tower that marks the southern entry into Kingston, the one at TOPO (Royal Exchange). This is clear from the Eden Quarter Development Brief which is an integral part of the Kingston Development Plan.
The 22-storey tower also destroys the view of the Guildhall as viewed from where the Hogsmill River meets the Thames. It is beyond our comprehension why the Planners did not make it clear to the developer that any building taller than the existing Lever House would not be permitted on the strength of this view alone. To allow this would be a dereliction of duty on the part of our elected Councillors.
The 22 storey tower would overlook and overshadow the whole neighbourhood of the adjacent Conservation Area. It would loom over many individual houses and residential streets. It would cast a shadow over a significant part of the residential area compared to the current situation with Lever House.
The Tower in combination with very high Office Block development, overcrowd and obscure the views and appreciation of the Grade II Listed United Reformed Church and the Old Post Office and create an unwelcome barrier between the residential Conservation areas and the Kingston Old Town Centre - If approved the impermeability of the new layout will destroy Council’s new pedestrian linkages.
3. Affordable Housing
Housing is an extremely strong concern for residents but is always used as a weapon against residents by developers. In our experience, residents rarely say no to truly affordable housing. No sane person believes that Kingston’s housing needs will be addressed by more luxury gated developments with prices far in excess of those which most residents could truly afford.
While the developer speaks of 35% affordable housing being provided this amount to only around 50 out of 156 homes. This amounts to just under 7% by area of the entire development (both Phase 1 & 2) -It is highly misleading, and this should not drive the overdevelopment of this site.
Kingston Councils' Affordable Housing SPD states "The financial implications of complying with the affordable housing policy need to be factored into the land value when purchasing a site. If no regard is paid to these implications the resultant financial consequences will have to be borne by the developer."
Therefore, this should have been evaluated on the basis of the extant planning policies including the EQDB. It is not acceptable for the developer to contend - as they have- that the 22 storey tower needs to be that high to “fit in” the Affordable Homes in their validation.
Due to its excessive bulk, scale, height and massing, the development would fail to meet the requirements as set out in the Eden Quarter Development Brief SPD which remains a material consideration for ALL planning applications. It should be noted that many during the consultation process considered this Supplementary Planning Document to be more than generous in its height guidance, so it is unacceptable for these constraints to now be ignored.
Their claim that the proposal is the most sustainable option is disingenuous when they plan to demolish a perfectly good office and multi storey car park only to rebuild them both with buildings with exactly the same functions. These buildings could be retained and refurbished. We can and should Recycle Buildings- not just bags! We should be upgrading existing buildings for extended use as a more carbon efficient alternative to demolition and new build whenever there is a viable choice.
The greenest building is the one already built - they should not pretend otherwise.
While the project may meet some sustainability requirements, small landscape adjustments and creating a slightly better river bank will not be enough to offset the damage created by demolishing an existing concrete building to the ground.
6. Parking, Transport, Infrastructure and Services
The submission largely underestimates the need for and impact on parking, transport, infrastructure and local services. This is already a busy and congested island and the additional office cars and residential drop off will exacerbate the traffic congestion- which incidentally will make the so called Hogsmill Park even more unpleasant.
7. Ineffective public consultation
The submission lists who and how much consultation was carried out but belittles voluntary community involvement and work that took place during the consultation. Despite the applicant’s protestations regarding a single website, the overwhelming response from the community is inaccessibility of information and clear answers from developers. Some of these issues are listed below: (for full list see pages 7-8)
> The period between the two consultations was too close for them to have considered feedback and make any meaningful adjustment to plans. (The first started on 29th June, the second on 3rd August, barely 4 working weeks between them.) This was just paying lip service to the process. The consultations were pointless and people who reserved their comments for the final exhibition were very disappointed with the lack of progress. This is the real reason why most reserved their opinions in the first one and opposed the proposals in the second consultation.
> In terms of usability, the exhibition website designed for the consultation was very poor. The image carousel did not work or was too slow on some handheld devices. The comments page did not work on some phones. Most downloaded PDF version in order to “view” the site but probably did not try to comment via email. People did not spend more than 2 minutes and 55 seconds (according to the Applicant’s report) because there was really not much to see.
> Both consultations lacked verified key views. In particular, the absence of a tall buildings angle was notable in the limited number of visuals provided. This was demonstrably misleading as it gave no clarity of how these buildings will be seen in context. The proposals dwarf the scale and massing of Royal Exchange and Eden Walk.
> There were no hard copies for anyone who was not able to view and/or download materials on line.
> There were no webinar or Zoom-type arrangements for residents to “meet the Architect/Developer”. The text-based “chat” facility was useful, but this should not have been the only means for Q&As. It is not something that all residents would use comfortably and showed a lack of awareness of the needs of different demographic groups in the community. The developers do not seem to have made any real effort to involve the community but rather have seen it just as a hurdle to overcome at the last minute.
> Covid has been used as an excuse. The applicant did not display their plans anywhere in the town. Expecting everyone to be able to read small architectural visuals or on the same digital footing in terms of accessing the online presentation fully was frustrating for some.
> Residents wanted to find out more about what the “Corporate Campus” would look like and explore the issues around the permeability to the town centre and from neighbouring residential areas. None of these could be explored in their image carousel. A large 3D model or printouts could have improved the legibility of the plans.
8. Public Realm
In the published Eden Quarter Development Brief the Council promised us a public square in front of the United Reformed Church and Old Post Office Building. This was meant to be a new public space
to balance the market place and be an area to meet and enjoy the heritage assets whilst shopping. What happened to that promise? What is created in the drawings is a space purely for the occupiers of the building. The curve of the building denotes the movement of the street it does not create a space. A stepped entry to the building is hardly a public square by any leap of the imagination.
The view of the Old Post Office and United Reformed Church facades are obscured from entry points to the “square” by the corners of the building. The developer is desperately trying to persuade us that the works to the Hogsmill River is for the public benefit, but this IS already PUBLIC LAND. It is clearly being purloined into the grounds of the 22 storey tower to add value to their asset and provide views for the residents. The tower is damaging and harming the value of the towns Heritage Assets, - protected views of listed buildings and effectively appropriating publicly-owned land – to add value to their own. To add insult to injury, the main terrace overlooking the Hogsmill will be private.
Clearly the public are not welcome in the ‘Woodland Walk’ in the centre of the development. There is no way to see a way out through the space and it offers no short cut. The entrance by the tower will be gated and is very narrow and at the other end there is a service yard- hardly somewhere pedestrians will want to walk through or to. It is obvious, and by design, that the public is not meant to come into this space, gate or no gate.
The Woodland Walk is the same shape and size as the Apple Market but with 3 huge buildings and a 22 storey tower the space will see practically NO sun at any time of year. The developer shows pretty, sun-drenched perspectives but their own daylight study shows this is far from the truth. Even in the height of summer this area will be in perpetual shade apart from a tiny bit at the entrance to the office for an hour or so.
9. Kingston ‘Arc’ Question
If the Eden Campus Towers are approved this would create a very dangerous precedent which will be used by developers for ALL new sites surrounding Kingston’s Historic Centre. We have already seen the developers of Surrey County Hall point to Eden Campus as justification for proposing two 17 storey towers as part of development “Arc” round Kingston. This is unacceptable, there is only meant to be ONE tower that marks the southern entry into Kingston, the one at TOPO (Royal Exchange). Eden Campus developers seek to justify their tower on the basis that there are tall buildings next door and so it goes on!
To our knowledge Kingston Planning guides and consultations have NEVER envisaged clusters of towers. How can the council ignore its own planning guides which were the subject of extensive public consultation? To allow this would be a dereliction of duty on the part of our elected Councillors.
We feel very strongly that this dangerous precedent MUST NOT be allowed to go ahead especially as there has been NO public consultation to justify ANY deviations from the current Development Plan including the Eden Quarter Development Brief which would not permit any of these proposals
Background Information on KRA and our engagement process
The Kingston Residents' Alliance is made up of various local residents associations and social groups. As residents, we came together informally in 2014 as a result of the St George’s planning application, then called The Old Post Office and now known as The Royal Exchange.
In the case of Eden Campus, we received an email from the Applicant on 23rd June 2020 regarding their plans for the Eden Campus. Since that initial letter, we had numerous socially-distant meetings with various residents and groups. We informed each other about the current consultations and encouraged others to comment on the developers’ websites after reading their material and attending their limited “open chat” lines. Some of the letters were also sent to councillors, so that they were aware of the issues concerning their constituents.
Our collective concerns were:
- The unprecedented size of the tower and tall building clusters proposed, which are adjacent to 3 conservation areas
- The speed of the Applicant’s consultation process and the lack of credible and digestible information from the Applicant
- The previous Eden Quarter Development Brief seemingly being ignored despite being a material planning consideration. The latter having been the subject of community consultation. We were asking each other if the Council now following a new tall buildings policy on which they have neither consulted residents nor informed us;
- Recognising that the Council had already given a green light at the pre-planning stage and issued a press release on 2 October in support of such an impactful proposal, without thinking through the consequences of allowing a 22-storey tower on a site occupied by a 6-storey tower
- A complete lack of leadership and public engagement with residents from the Council’s planning department regarding our concerns above.
Based on their SoCI data, they managed to attract only 3,828 overall visitors. We also know that in Phase 1 of their consultation they had 834 visitors with 39 responders – (15 opposed, 4 no comment, 20 supporting). Phase 2 brought 1,258 visitors with 254 responders, of whom 227 opposed the proposals.
This means that roughly 84% of all respondents rejected the applicant’s plans
RESIDENTS COLLECTIVE CONCERNS REGARDING CONSULTATION PROCESS:
- The period between the two consultations was too close to make any meaningful adjustment to the plans. (The first started on 29th June, the second on 3rd August, barely 4 working weeks between them.) The consultations were pointless and people who reserved their comments for the final exhibition were very disappointed with the lack of progress. This is the real reason why most reserved their opinions in the first one and opposed the proposals in the second consultation.
- In terms of usability, the exhibition website designed for the consultation was very poor. The image carousel did not work or was too slow on some handheld devices. The comments page did not work on some phones. Most downloaded PDF version in order to “view” the site but probably did not try to comment via email. People did not spend more than 2 minutes and 55 seconds (according to the Applicant’s report) because there was really not much to see.
- Both consultations lacked verified key views. In particular, the absence of a tall buildings angle was notable in the limited number of visuals provided. This was demonstrably misleading.
- There were no hard copies for anyone who was not able to view and/or download materials on line
- There were no webinar or Zoom-type arrangements for residents to “meet the Architect/Developer”. The text-based “chat” facility was useful but should not have been the only means for Q&As. It is not something that all residents would use comfortably and showed a lack of awareness of the needs of different demographic groups in the community.
- The applicant did not display their plans elsewhere in the town. Expecting everyone to be able to read small architectural visuals or on the same digital footing in terms of accessing the online presentation fully was frustrating for some.
- Residents wanted to find out more about what the “Corporate Campus” would look like and explore the issues around the permeability to the town centre and from neighbouring residential areas. None of these could be explored in their image carousel. A large 3D model or printouts could have improved the legibility of the plans.
- Unilever’s involvement and potential jobs: Most residents in Kingston do welcome a major brand HQ moving to the town centre. In the middle of a pandemic and the consequent death of high street footfall, we can all see that this could be a major boost to the town centre and jobs. However, when we tried to find out more about what exactly Unilever’s commitment is to this development or whether the land owner is using this as a land speculation exercise we did not receive any clarity. This raises serious questions. Unilever is already committed to a long lease on Lever House. We know that that Unilever has been moving their staff around Surrey for over a decade and they left West Drayton and Richmond for Leatherhead in 2013. So, the question is are they contractually committed to relocate more jobs to Kingston and, if so, for how long? Is there an NDA in place that restricts the Council from communicating with residents? These are all legitimate questions to which the consultors failed to respond. We understand corporate moves are complicated, but it would have been nice if the questions surrounding Unilever’s involvement were properly answered given the importance to the town and the fact that the Leader of the Council came out so strongly in favour of the proposals.
- The applicant failed to explain how they arrived at a 22-storey idea in the first place. Surely after the colossal fight local residents mounted against St George’s and British Land only a few years ago, officials at the Council should have been aware that local residents have no appetite for another overdevelopment on their doorstep. When asked, the applicant could not confirm on which planning policy document their proposal was based, but they told us it was approved by “the Council” at the pre-planning stage in March. This seems unlikely, when the entire country was shut down with Covid? From the pre planning advice it would seem a letter from you as the Head of Development Management has led them down this path.
- If it goes ahead this development will be one of tallest buildings in the borough, one to
match the Tolworth Tower. From what was exhibited, visitors could see little consideration to mitigate any wind speed or turbulence or the overshadowing effects on the immediately surrounding housing, most of which is in a conservation area. This is something heavily explored only a few years ago around TOPO tower and that is 30m lower in height than the proposal here.
- Around the same time as this application, the ‘Arc of Towers’ concept was presented by the Surrey County Hall developers. Clearly the entire area now is being seen as a “tower building opportunity” by developers. Far from being a symbol of sustainability, the evidence across the London points to a highly problematic urban typology and an absence of happy neighbourhoods. Kingston residents are aware of the many problems with tall buildings, on social, economic and ecological grounds and firmly do not want the same in their in their town.
- Design and density are important areas properly explored by heritage and planning focused groups. However, residents’ comments mostly focused on how the development is so out of character with the adjacent conservation areas and how detrimental its effect will be on immediate surroundings. People just could not understand how this could even be seriously considered? Surely, the Council could see the proposed tower will rise above the historic skyline, spoiling the view from the market square and other key locations?
- There are many unanswered infrastructure questions. The consultation largely ignored or did not understand the need for and impact on parking, transport, infrastructure and local services. There was no provision within the proposals for a strategic transport and public services solution.
- In respect of the Hosgmill River and sustainability questions, there was no obvious answer to street permeability, wind tunnel and sun/light issues around the Hosgmill. How could this development claim to be sustainable whilst demolishing an existing concrete building to rebuild a 22-floor luxury tower block? Large buildings come with a huge environmental cost, despite our best efforts to offset CO2 and use more environmentally-friendly materials. While the project may meet some sustainability requirements, small landscape adjustments and creating a slightly better river bank will not be enough to offset the damage created by demolishing an existing concrete building to the ground.
- Housing – affordable housing is an extremely strong concern for residents but is always used as a weapon against residents by developers and the Council. In our experience, residents rarely say no to truly affordable housing. Residents’ scepticism is based on past experiences with similar developments. No sane person believes that Kingston’s housing needs will be addressed by more luxury gated developments with prices far in excess of those which most residents could truly afford.
In the SoC report, the applicant refers to a “stock response” by residents. We find it amusing that when neighbours collaborate on how to respond to a complex planning application, we are equally fed up with the “stock response” when we raised the affordability issue with their almost identical viability report response. The widely-held belief is that this type of riverside development will never be truly affordable to any local resident but does generate a healthy profit margin for the developer.
- Finally despite weeks of voluntary community work, in the midst of a Pandemic, it was disappointing to read the Statement of Community Involvement where the Applicant suggests that they wrote to local groups (including Kingston Society, United Reform Church, Kingston University, College and KRA) and “we did not give any response”. It is telling that the only response they seem to be acknowledging is from the Council leadership, Party Groups, Kingston First, Chamber of Commerce and GLA.